The Strategic Choice After Reassessment
Jennifer is an associate lawyer at Counter Tax Litigators. Her practice encompasses all aspects of tax controversy and litigation.
Jennifer has represented clients in appeals before the Tax Court of Canada and Federal Court of Canada. She regularly works on complex objections and audits for private companies and high-net-worth individuals involving international and domestic issues.
Jennifer has successfully resolved tax controversies involving residence for tax purposes, GST/HST, applications for judicial review, shareholder and employee benefits.
Jennifer is a mentor with the Federation of Asian Canadian Lawyers. Each year, she helps two Asian Canadian law students navigate the legal profession.
- Verified Client Feedback for the Legal 500: 2024 Elite Tax Boutique Award
- Kuldeep Sharma, President, Courtyard by Marriott Toronto/Brampton
- Vikram Gulati, CPA, CGA
- Narinder Seehra, CEO, MSR Holdings Inc.
September 07, 2025 - Peter Aprile, Senior Counsel at Counter LLP, describes three inflection points that define how CRA challenges develop and are resolved. The framework reflects insights drawn from years of...
August 21, 2025 - Key Takeaways Benefit without cost invites scrutiny: Courts scrutinize tax structures that offer benefit without tradeoff, and when they find this gap, they side with the CRA and uphold the...
August 14, 2025 - Key Takeaways No inference of intent: Courts rejected the claim that surplus cash was earmarked for decommissioning in the absence of contemporaneous reserves, allocations, or disclosures. ...
August 11, 2025 - Key Insights at a Glance Deferral as strategy: Departure tax can be deferred without interest when acceptable security is posted, preserving liquidity during transition. Forms of security: CRA...
June 30, 2025 - Key Takeaways Forum defines outcomes: The taxpayer’s appeal was quashed without the merits ever being heard because the chosen forum lacked jurisdiction. Procedure equals substance: Courts...
June 05, 2025 - Key Takeaways Framing gap: The Tax Court accepted CRA’s framing because Vortex’s reply lacked engineering support and legal positioning. In other disputes, when claims were framed with qualified...